DIN deactivation and director disqualification under the Companies Act cannot be used to block statutory compliance and filings.

The Companies Act framework on disqualification and DIN deactivation was examined under Sections 164(2)(a) and 167(1) read with Rules 10(6), 11 and 14 of the Companies (Appointment and Qualifications of Directors) Rules, 2014. The governing principle is that the Registrar of Companies has no power to deactivate a Director Identification Number merely because a director is disqualified. Such deactivation is inconsistent with the statutory scheme, because a disqualified person may still need the DIN to regularise filings and comply with obligations for the defaulting company. The earlier binding view was followed, and DIN deactivation could not be sustained.

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Issues: Whether the Registrar of Companies could deactivate the Director Identification Number and disable the petitioners from continuing or seeking appointment as directors on the basis of disqualification under the Companies Act, 2013.

Analysis: The basis for the disqualification and consequent deactivation had already been examined in earlier decisions. The governing provisions of Section 164(2)(a) and Section 167(1) of the Companies Act, 2013, together with Rules 10(6), 11 and 14 of the Companies (Appointment and Qualifications of Directors) Rules, 2014, were considered. It was held that the Rules do not confer power on the Registrar of Companies to deactivate the DIN merely because a director is disqualified. The deactivation was also found to be inconsistent with the scheme of Section 164(2) read with Section 167(1), since a person may continue to remain a director of the defaulting company and would need the DIN to regularise filings and comply with statutory requirements.

Conclusion: The deactivation of DIN could not be sustained and the petitioners were entitled to relief following the earlier binding decision.

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